of the land to answer. The Master of the Rolls held, after argument by counsel, that there was no privilege, and he overruled the demurrer. Fr. Gahan adhered to his refusal to answer and he was adjudged guilty of contempt of court and was briefly imprisoned. This did not end the litigation which went on until 1808, and resulted in a compromise. Precedent overturned This authority was decisively rejected by the President of the High Court of Ireland in 1945 in Cook v Carroll, where he found that a priest has an absolute privilege not to reveal what is said in the confessional. References Bibliography Nolan, R. S. (1913) "The Law of the Seal of Confession", Catholic Encyclopaedia 1802 in British law Irish case law 1802 in case law Priest–penitent privilege in England 1802 in Ireland Evidentiary privilege case law